ML13261A212

Request for Additional Information Email, Exemption Request, Use of Less Restrictive Work Hour Limitations During First 60 Days of Outage, in Lieu of 10 CFR 26.205(d)(7)

ML13261A212
Person / Time
Site:	Fort Calhoun
Issue date:	09/18/2013
From:	Joseph Sebrosky Plant Licensing Branch IV
To:	Hansher B Omaha Public Power District
Sebrosky J
References
TAC MF2571
Download: ML13261A212 (2)

Text

Burkhardt, Janet From: Sebrosky, Joseph Sent: Wednesday, September 18, 2013 11:35 AM To: bhansher@oppd.com Cc: medwards@oppd.com; Wilkins, Lynnea; Martin, Kamishan; Galbreath, Stephanie; Markley, Michael; Hay, Michael; Franklin, Carmen; Shoop, Undine; Burkhardt, Janet

Subject:

Request for Information Associated with August 16, 2013, Work Hour Exemption Request (MF2571)

Mr. Hansher, By letter dated August 16, 2013 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML13231A018) as supplemented by letter dated August 30, 2013 (ADAMS Accession No. ML13246A182), Omaha Public Power District (the licensee) submitted for Nuclear Regulatory Commission (NRC) approval a request for an exemption from requirements of paragraph 26.205(d)(7) of Title 10 of the Code of Federal Regulations (10 CFR) for Fort Calhoun Station, Unit No.1. The proposed exemption would approve an exemption from specific requirements of 10 CFR 26.205(d)(7), to allow the use of the less restrictive work hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to support activities required for plant startup from the current extended outage, for a period not to exceed 45 days.

Based on a review of the submittal, the NRC staff has determined that the following additional information (RAI) is required in order to complete its review. The request for additional information was discussed with you on September 18, 2013. It was agreed that a response to these RAIs would be provided by September 23, 2013. Should the NRC determine that these RAIs are no longer necessary prior to the scheduled date, the request will be withdrawn. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1132 or via e-mail at joseph.sebrosky@nrc.gov. The NRC staff has determined that no security-related or proprietary information is contained herein.

Sincerely, Joe Sebrosky Project Manager Nuclear Regulatory Commission Division of Operating Reactor Licensing joseph.sebrosky@nrc.gov 301-415-1132 Request For Information

1. OPPD focused the efforts on emergent issues during the period that was granted the first time. What is the relationship between the emergent issues addressed during the previous exemption period and the schedule for startup activities for exemption from Part 26, subpart I?

2. What is the status of the work described in the response to the clarifying question 1 found in the August 30, 2013, supplement (ADAMS Accession No. ML13246A182)? Specifically, the work related to the unevaluated high energy line break in the steam supply to the aux feed water turbine inside room 19 & the high pressure safety injection issue which was not balanced in the Updated Safety Analysis Report.

3. It was stated in the response to clarifying questions 1 found in the August 30, 2013, supplement (ADAMS Accession No. ML13246A182) that the 45 day exemption request is for the completion of emergent issues 1

as well as activities associated with restarting the plant. Please describe the relationship between the emergent issues and the activities required for plant start up from this extended outage. In the introductory paragraphs of the August 16, 2013, and August 30, 2013, submittals, this 45 day exemption is explicitly requested for start up activities but in the response to the first question found in the August 30, 2013, supplement it is stated that the 45 days would be used for both resolving emergent issues and for start up activities. Which is it? What is the plan/path forward that would ensure that all 45 days are necessary and that all the work that is planned can be completed within 45 days with the relaxed work hour requirements?

4. The exemption request allowed covered workers to work hours necessary to install the physical modifications needed to protect the tornado missile vulnerabilities in an expeditious manner. Are these activities associated with the start-up check list? Was there work done by individuals that were not considered to be covered as determined by a risk informed evaluation due to current plant configuration? Was it a consideration that this work would be completed in the 60 days such that start up activities could also be completed?

5. Currently, does the licensee have any equipment reliability concerns that would affect the proposed schedule in such a way that the 45 days requested would not be sufficient? If so please describe.

6. As provided in supplemental information to the exemption request dated August 30, 2013, the licensee provided the average hours worked by various groups of personnel subsequent to the ending of the initial exemption period. Please confirm the planned schedules for personnel going forward until the proposed start date of the second exemption period.

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